QC TECH LLC PRIVACY POLICY

Effective date: September 16, 2026

1) Introduction

This Privacy Policy explains how QC Tech LLC (d/b/a Polymarket App), (“Company,” “we,” “us,” or  “our”) collects, uses, shares, and safeguards personal information of users of the Polymarket software application (the “App”) and the Polymarket.us website (“the Website”) (the Website and App  collectively, “Platform”). We encourage you to carefully and regularly review this Privacy Policy.  

Your use of the Platform is subject to the QC Tech LLC Terms & Conditions, the Polymarket US  Rulebook, the Polymarket Clearing Rulebook, the Participant and Clearing Member Agreement, and the  Risk Disclosure Statement provided by Polymarket US (QCX LLC) and Polymarket Clearing (QC  Clearing LLC) (collectively, “Terms”). If you do not agree with the Terms, or the collection and use of  your personal information as described in this Privacy Policy, please do not access or use the Platform.

2) Applicability

This Privacy Policy applies to all information we collect from you in connection with your use and our  provision of the Platform. This Privacy Policy does not apply to information collected on any other  application or website made available by us that does not display this Privacy Policy or on any other  websites offered by any third party (including our affiliates and subsidiaries).  

For more information about how Polymarket US (QCX LLC) and Polymarket Clearing (QC Clearing  LLC) process your personal information to facilitate trading on the exchange and/or clearing services in  connection with your use of those services, please see the privacy policy located at https://polymarketexchange.com/.

Throughout this Privacy Policy, we use the term “personal information” to describe information that we  collect, process, use, and disclose. “Personal information” includes any information that, alone or in  combination with other information, relates to, describes, is reasonably capable of being associated with,  or could reasonably be linked, directly or indirectly, with an individual. It generally means the same as the  terms “personally identifiable information,” or “personal data,” as defined under applicable data  protection laws.

Please note, however, that under applicable state-level privacy laws, personal information does not  include certain information, including:

• de-identified or aggregated information;

• publicly available information, such as public records held by the government or data made  publicly available by you or with your permission;

• protected health information handled by a covered entity or business associate and/or governed  by the Health Insurance Portability and Accountability Act of 1996 (HIPAA) or the Health  Information Technology for Economic and Clinical Health Act (HITECH);

• medical information protected under state law; or

• personal information protected by federal laws such as the Fair Credit Reporting Act (FCRA), the  Gramm-Leach-Bliley Act (GLBA), the Driver’s Privacy Protection Act of 1994 (DPPA) and the  Family Educational Rights and Privacy Act (FERPA).

3) Sources of Information

We collect personal information from various sources, including:

• directly from you when you provide it to us,  

• automatically when you use the Platform,  

• from third parties, such as our business partners, third party service providers, advertising  partners, affiliates, and social media platforms or networks,

• from designated contract markets (“DCMs”), futures commission merchants (“FCMs”) / clearing  members, other intermediaries, independent software vendors (“ISVs”), introducing brokers  (“IBs”), and from public or governmental sources, and

• publicly available sources.

4) Personal Information Collection

We may collect information about you and your use of the Platform, including:

• Personal information, such as full name, date of birth, government-issued identifiers, profile  picture, email address, physical address, and phone number.

• Derivative information, such as device and usage data (IP address, device/OS/browser, unique  IDs, logs, duration, activity, pages you navigate through on the Website and pages viewed  directly before and after accessing the Website); location data; communications (support tickets,  recordings, emails/chats); technical and usage data; and data collected automatically via cookies  and other tracking technologies.

• Financial information and information required for regulatory compliance, such as wallet ID,  bank/payment information, balances, transactions; account and trading data (credentials, orders,  executions, positions, balances, audit metadata); know your customer (“KYC”) / anti-money  laundering (“AML”) / counter-terrorism financing (“CTF”) data (verification results,  sanctions/politically exposed person checks).

• Mobile Device Information, such as device type, mobile device identification number,  geolocation information, time zone, language setting, and browser type.  

• Geolocation Information. We collect information that identifies, with reasonable specificity, your  location by using certain longitude and latitude coordinates obtained through GPS (for Android  users), Wi-Fi, IP-based estimation, or other locational data. We may collect this data for fraud  prevention and risk management purposes, among other reasons identified in this Privacy Policy.

• Correspondence and Recordkeeping. We will retain records and copies of your correspondence  (including e-mail addresses) if you contact us. We will retain all records for such time period as  may be required or permitted by applicable law.

• Surveys and Public Chat Forums. If you decide to participate in surveys or publicly available  chat forums available via the Platform, you may be asked to provide certain information in your  responses, which may include personal information. We may store such responses and the  messages that you make available on the chat forums.  

We may collect other information, including personal information, with your consent. 5) Use of Tracking Technologies

When you use the Website, we and certain business partners and vendors may use cookies and other  tracking technologies (collectively, “Cookies”). A cookie is a small file placed on the hard drive of your  computer. Cookies may automatically collect certain information, such as a website visitor’s device’s IP  address, browser type, operating system, computer platform, web pages viewed, and/or the date and time  of the website visit. We use Cookies to recognize you as a customer; to customize our services, including  advertising provided to you; to measure the effectiveness of our promotions; to support the functioning of  the Website; to perform a wide range of analytics; to mitigate risk and prevent potential fraud; or otherwise  as described in this Privacy Policy.

Most browsers are set to accept cookies by default, and you may be able to reject cookies through your  browser settings. However, some of our services are only available through the use of Cookies. Therefore,  if you choose to disable or decline Cookies, your use of the Website may be limited or not possible.

Pages of the Website may contain small electronic files known as web beacons (also referred to as clear  gifs, pixel tags, and single-pixel gifs) that permit us, for example, to count users who have visited those  pages and for other related website statistics. You may not decline web beacons. However, you may be able  to modify your web browser’s settings to render web beacons ineffective.

Third parties may use Cookies on the Website (either alone or in conjunction with web beacons or other  tracking technologies) to collect information about you when you use the Website. This information may  be associated with other personal information about your online activities over time and across different  websites and online services. Third parties may use this information to provide you with interest-based  advertising or other targeted content.  

The Website uses Google Analytics. For more information on Google Analytics and other Google tracking  technologies, please visit the sites below:

• For Google Analytics, visit: https://www.google.com/analytics. Google Analytics is a web  analytics service offered by Google that tracks and reports website traffic. Google uses the  data collected to track and monitor the use of the Website. This data is shared with other  Google Services. Google may use the collected data to contextualize and personalize the ads  of its own advertising network. For more information on Google Analytics and other Google  tracking technologies, please visit https://policies.google.com/. We also encourage you to  review Google’s policy for safeguarding your data:  https://support.google.com/analytics/answer/6004245.

• For Google AdWords, you can set preferences for how Google advertises to you using the  Google Ad Preferences page at: https://adssettings.google.com/authenticated.

Do Not Track: Do Not Track (“DNT”) is an optional browser setting that allows you to express your  preferences regarding tracking by advertisers and other third parties. You can enable or disable DNT by  visiting the preferences or settings page of your web browser. The Website does not respond to DNT signals.

We and our partners may use various technologies—including your device’s mobile advertising ID and  embedded software development kits (“SDKs”)—to gather personal information about your use of and  engagement with the content on the App. This information may be combined with other data we collect  

and store about you and/or transmitted to third parties, such as our advertising partners. We and our  partners may collect your personal information about your online activities over time and across different  websites when you use the App. The use of these technologies helps us serve you better by understanding  what you are interested in, tracking trends, measuring the effectiveness of ads, saving your preferences,  and storing information you may want to retrieve on a regular basis. In addition, our advertising partners  may use this information to deliver advertisements to you when you visit third-party websites within their  networks. Your device may permit you to control these technologies. For instance, you may be able to opt-out of having your mobile advertising identifiers used for certain types of targeted or personalized  advertising by accessing the settings in your mobile device.

6) How We Use Personal Information

We use personal information collected about you for various purposes, including:

• To provide, operate, customize, personalize, measure, and improve the Platform, and the content  and layout of the Platform;

• To process transactions (including payments and refunds) and send notices about your  transactions or your network activity;

• To contact you regarding your use of the Platform, including responding to questions or requests  you may have with respect to the Platform;

• To measure interest and engagement in the Platform and short-term, transient use, such as  contextual customization of ads;

• To market to you and provide targeted advertising, coupons, newsletters, and other promotional  information regarding the Platform (including marketing conducted by our business partners and  affiliates);

• To compile statistical data and analysis for our use internally or by third parties;

• To ensure internal quality control, including to debug, identify and repair errors that impair  intended functionality or improvements to the Platform;

• To safeguard the Platform, detect security incidents, protect against malicious, deceptive,  fraudulent or illegal activity, and prosecute those responsible for that activity;

• To verify your identity, and prevent fraud, market abuse, prohibited or illegal activities, including  through the use of our risk and fraud tools;

• To offer certain features or functionalities through the Platform, which may involve interacting  with artificial intelligence technology or tools;

• To enforce our Terms, and protect the rights, property, or safety of us or others;  

• To respond to lawful requests by public authorities, or where otherwise required by law, court  order, or other law enforcement or regulatory authority;  

• To evaluate or conduct a merger, divestiture, restructuring, reorganization, dissolution, or other  sale or transfer or some or all of our assets, whether as a going concern or as part of bankruptcy,  liquidation, or similar proceeding, in which personal information held by us is among the assets  transferred;

• To comply with legal/regulatory obligations (including Commodity Futures Trading Commission  (“CFTC”), AML/KYC/CTF, sanctions, surveillance, audit trail, and recordkeeping  requirements); and

• As otherwise described to you when collecting your personal information, for any other purpose  for which you provide consent, or as otherwise required or permitted by law.

We may aggregate, anonymize, and/or de-identify information such that it cannot be used to identify you  and is not considered personal information under applicable laws. We use this information for product  development and improvement, and other business activities.

7) To Whom We Disclose or Share Personal Information

Some personal information is public information (such as chats you may post in chat forums on the  Platform) and may be seen by anyone on the Internet, whether or not they have an account with us. Public  information may also be seen, accessed, reshared or downloaded through APIs, SDKs, or third-party  services that integrate with our Platform.

With respect to other personal information, we may disclose your personal information to:

• Third-party service providers, including artificial intelligence tool providers and those that assist  us in fraud detection, KYC/AML/CTF obligations, and prevention or otherwise assist in  providing the Platform to you, such as DCMs, DCOs, FCMs, brokers, ISVs, IBs, surveillance  providers, KYC/AML/CTF vendors, cloud and infrastructure providers, payment partners, banks,  and other third-party service providers.

• Our parent companies, affiliates, subsidiaries, joint ventures, or other companies under common  control or related by common ownership or control that assist us with providing the Platform,  including associated KYC/AML/CTF services and trading and/or clearing services (such as QCX  LLC and QC Clearing LLC).

• Successor(s) of our business, relating to all or part of the business, to evaluate a proposed  transaction or sale, reorganization, merger, acquisition, or other change of control.

• Other individuals who have referred you to our Platform.

• Other third parties or nonaffiliates as permitted by law or contract, to provide the Platform, or to  protect our or other’s rights, property, or safety.

• Law enforcement, government officials, or other third parties if we are compelled to do so by a  subpoena, court order or similar legal procedure, when it is necessary to do so to comply with  law, or where the disclosure of personal information is reasonably necessary to prevent physical  harm or financial loss, to report suspected illegal activity or other unfair trading practices, to  investigate violations of the Terms, as otherwise required by law; the CFTC in accordance with  regulatory requirements; or whenever we believe in good faith that disclosing such information is  necessary or advisable.

• If you authorize an account connection with a third-party account or platform, we may disclose  your personal information to such third-party account or platform:

o For the purposes of this Privacy Policy, an “account connection” with such a third party  is a connection you authorize or enable between your account and a payment instrument,  or platform that you lawfully control or own. When you authorize such a connection, we

may exchange your personal information directly with such third-party. Examples of  account connections include, without limitation: linking your account to a social media  account or social messaging services; connecting your account to a third-party data  aggregation or financial services company, if you provide such company with your  account log-in credentials; or using your account to make payments to a merchant or  allowing a merchant to charge your account.

o If you connect your account to other financial accounts, directly or through a third-party  services provider, we may have access to your account balance and account and  transactional information, such as purchases and funds transfers. If you choose to create  an account connection, we may receive information from the third party about you and  your use of the third-party’s services. For example, if you connect your account to a  social media account, we will receive personal information from the social media  provider via the account connection. We will use all such information that we receive  from a third-party via an account connection in a manner consistent with this Policy.

o Information that we share with a third party based on an account connection will be used  and disclosed in accordance with the third party’s privacy practices. Before authorizing  an account connection, you should review the privacy notice of any third party that will  gain access to your personal information as part of the account connection.

We may also share or license your personal information with business partners and other third parties so  that those third parties can offer you certain products, services, and promotions. Additionally, we may  also use third-party advertising companies to serve ads when you visit the Platform, and those advertising  companies may use information about your visits to the Platform and other websites that are contained in  tracking technologies in order to provide advertisements about goods and services of interest to you. You  may be entitled to prevent us from sharing and/or licensing your personal information to other companies  under applicable law. If you wish to exercise this right, please send an e-mail to legal@polymarket.com.

We may use your personal information and proprietary data for business or marketing purposes in  addition to using such information for the purpose of complying with regulatory obligations, and we may  disclose personal information and proprietary data to our affiliated entities for their business or marketing  purposes. You may opt out of us using this information for business and marketing purposes by  contacting us at legal@polymarket.com. We do not condition access to our trading facility on your  consent to the use of personal information or other information for our business or marketing purposes.  Where necessary, we may disclose personal information to one or more DCMs, swap execution facilities,  or derivatives clearing organizations registered with the CFTC.

We may disclose your personal information for additional purposes and/or to other third parties with your  consent or at your direction. We may also disclose aggregated or de-identified data with third parties who  may use that information for other purposes.

8) Data Retention

We will keep your personal information for as long as necessary for the purposes identified in this  Privacy Policy or to fulfill the purpose(s) for which it was collected, or as permitted or required by  applicable law or our legal obligations.  

9) Security

We implement administrative, technical, and physical safeguards that are designed to help protect your  personal information. Please be aware that despite our efforts, no data security measures can guarantee

security, and no method of transmission over the Internet or electronic storage is 100% secure. Therefore,  we urge you to take adequate precautions to protect your personal information as well, including by not  re-using or sharing your password. Any transmission of personal information is at your own risk. We are  not responsible for circumvention of any privacy settings or security measures on the Platform.

10) Transfer of Data

By using the Platform, you consent to the transfer of your information outside of your country of  residence, which may have data protection rules that are different from those of your country. For  example, we may store, process, use, and disclose personal information in the United States. In certain  circumstances, courts, law enforcement agencies, regulatory agencies or security authorities may be  entitled to access your personal information.

11) Your Rights and Choices

Subject to certain exemptions under applicable law, you may have certain rights related to your personal  information.  

i. Right to access. You have the right to access, know about, or confirm the processing of your  personal information, including the categories of, and sources of, personal information that we  collect about you, the business or commercial purpose(s) for collecting, selling, or sharing your  personal information, the categories of third parties to which your personal information is disclosed,  and the specific pieces of personal information we have collected about you.

ii. The right of correction or rectification. You have the right to have your information rectified if  that information is inaccurate or incomplete.  

iii. The right to object. You have the right to object to certain processing of your personal information,  such as processing for direct marketing purposes.

iv. The right of restriction. You have the right to request that we restrict the processing of your  sensitive personal information.

v. The right to data portability. You have the right to be provided with a copy of your personal  information in a structured, machine-readable and commonly used format, to the extent technically  feasible.  

vi. The right to withdraw consent. You also have the right to withdraw your consent at any time  where we rely on your consent to process your personal information.

vii. The right to erasure. If you wish to discontinue the use of the Platform, you have the right to  request that we delete your personal information.

viii. The right to opt-out of the “sale” or “sharing” of your personal information, or the use of your  personal information for “targeted advertising” (as these terms are defined under applicable privacy  laws). Please note that we may disclose your personal information to individuals who have referred  you to the Platform, to our third-party business partners for their marketing purposes, and as  otherwise described in this Privacy Policy. The information we may disclose may include your  personal information and information about your use of the Platform. To opt out of the sale or  sharing of your personal information, please contact us at legal@polymarket.com.

You will not be discriminated against for exercising any of these rights. To exercise your choices and  rights, please contact us using the contact information provided in this Privacy Policy. We may  request or require additional information to verify your identity to fulfill your request.  

However, we may deny certain requests: (a) when denial of access is required or authorized by law; (b)  when granting access would have a negative impact on another's privacy; (c) to protect our rights and  property; or (d) where the request is frivolous or vexatious, or for other reasons permitted by law.

You may designate an authorized agent to make a request on your behalf. Authorized agents will be  required to provide proof of their authority to act on your behalf by providing relevant documentation.  We may contact you to confirm an authorized agent’s representation and to verify your identity.

12) Children Under the Age of 18

The Platform is not intended for individuals under the age of 18, and we do not knowingly collect, sell,  share, or disclose the personal information of minors under the age of 18. If you are aware of an instance  in which we have collected a minor’s personal information, please report it to legal@polymarket.com; we  will delete the minor’s personal information where required, subject to regulatory retention obligations.

13) Third-Party Links and Services

The Platform may contain links to (or allow you to link to) unaffiliated third-party services, applications,  or websites. We do not control information collection of any third-party services, applications, or  websites that can be reached through such links. We encourage our users to be aware when they are  linking to a third-party service or website and to read the privacy statements of any third-party service or  website that collects personal information. Any information you provide to any third party is not covered  by this Privacy Policy and we cannot guarantee the safety and privacy of any information you provide to  such third parties.

14) Personal Communication Preferences

If required by law, we will request your consent to send you marketing text messages and phone calls. You  may manage your receipt of marketing and non-transactional communications from us by clicking on the  “Unsubscribe” link located on the bottom of any marketing communication, replying STOP to a marketing  text message, changing your settings on the Platform, or by sending us an email  at support@polymarket.us with the subject line, “Unsubscribe from Marketing.” Registered users cannot  opt out of receiving transactional or administrative emails related to their account. We will use  commercially reasonable efforts to process such requests in a timely manner, in compliance with applicable  laws. In connection with our use of SMS messaging, no mobile information will be shared with third parties  or affiliates for their marketing or promotional purposes. Any sharing with third parties for any other  purpose will not include your phone number and opt-in data, unless permitted or required by applicable law  and for the purposes described in this privacy policy, such as fraud detection.

15) Automated decision-making and profiling

We may use automated tools for fraud detection, sanctions/KYC/AML/CTF screening, surveillance, and  risk controls. These automated tools may include artificial intelligence tools.

16) Changes to this Privacy Policy

We may update this Privacy Policy from time to time. When we do, we will revise the updated date at the  top of this page. We encourage users to frequently check this page for any changes to stay informed about  our information practices. You acknowledge that it is your responsibility to review this Privacy Policy  periodically and become aware of modifications. Your continued use of the Platform following the  posting of changes to this Privacy Policy will be deemed your acceptance of those changes.

17) Contact us

For questions or concerns about our privacy practices, please contact:

QC Tech LLC

Attn: Privacy

169 Madison Ave, STE 16385

New York, NY 10016

Email: legal@polymarket.com

Phone Number: +1 201-293-6079

18) CFTC/DCM-specific disclosures

We and connected DCMs/FCMs/ISVs/market-surveillance providers collect and retain order, trade, and  other audit-trail data to meet CFTC and exchange obligations. Certain personal information cannot be  deleted until legal retention periods expire. We may monitor activity for abusive trading patterns and  disclose data to regulators as required.

19) State-Specific Privacy Notice

U.S. state laws, including the California Consumer Privacy Act, require us to disclose the following  additional information with respect to our privacy practices. If you are a California resident or a resident  of a state that requires us to provide certain privacy-related disclosures, this section applies to you in  addition to the rest of the privacy policy.

California Shine the Light Disclosure

We will provide information about the types of personal information as defined by California Civil Code  § 1798.83 (the “Shine the Light Law”) that we may share with or disclose to third parties, other than our  affiliates, for their direct marketing purposes. If you are a California resident, you may request  information about our compliance with the Shine the Light Law by contacting us. Any such request must  include “Request for California Privacy Information” in the subject line and include your name, street  address, city, state, and ZIP code. Please note that we are only required to respond to one request per  customer each year, and we are not required to respond to requests made by means other than through the  email address or mailing address referenced above.

Categories of Personal Information that We Collect and Disclose

You can find a list of the categories and examples of personal information that we collect in the “Personal  Information Collection” section above. For details regarding the sources from which we obtain personal  information, please see the “Sources of Information” section above. We collect and use personal  information for the business or commercial purposes described in the “How We Use Your Personal  Information” section above.

In the last 12 months, we have disclosed the following categories of personal information to various third party recipients:

Sensitive Personal Information

We only collect sensitive personal information, as defined by applicable privacy laws, for the purposes  allowed by law or with your consent. We do not collect or process sensitive personal information for the  purpose of inferring characteristics about you.

Rights Available under California Law

For information about the rights that may be available to you under California law and how to exercise  those rights, please see the “Your Rights and Choices” section above.

Appeals  

Depending on applicable law, you may have the right to appeal our decision to deny your request or a  request submitted by an authorized agent on your behalf. To submit an appeal, please contact us.

Notice of Financial Incentives  

From time to time, we may offer financial incentives in connection with the collection or use of personal  information. For example, we may provide financial incentives to you if you refer other individuals to the  Platform using a unique website URL provided to you. To the extent that you provide this URL to other  individuals, you agree and understand that you must have the consent of the individual to provide this  referral, and you must provide the individual with a link to this privacy policy along with the URL. We  may also provide credits for services on the Platform in exchange for you registering for an account on the  Platform. The material terms of the financial incentive will generally be presented to you at the time you  sign up. You may withdraw from any financial incentive at any time by contacting us. However, if you ask  us to withdraw any financial incentive, we may be unable to return previously provided incentives at a later  time.